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Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Susan M. Kirsch has joined our teams as Government Affairs Advisor. Ms. Kirsch brings substantial regulatory and technical policy expertise at the local, state, and federal levels, with experience at the New York State Department of Environmental Conservation, the U.S. Department of Justice, Environmental and Natural Resource Division, and most recently the Association of Clean Water...

EPA Issues Final RMP Rule: On January 13, 2017, EPA published in the Federal Register its final rule amending the Accidental Release Prevention Requirements for Risk Management Programs (RMP) under Clean Air Act (CAA) Section 112(r)(7). 82 Fed. Reg. 4594. The amendments are intended to modernize EPA’s RMP regulations as required under Executive Order (EO) 13650, which directs the federal government to carry out certain tasks intended to...

The Acta Group (Acta®) is pleased to announce that Zameer Qureshi, a chemical regulatory and international business lawyer based in the United Kingdom (UK), has joined our team as Legal Consultant to The Acta Group EU, Ltd (Acta® EU). Mr. Qureshi has an in-depth understanding of UK and European Union (EU) laws related to Acta EU's practice areas, and he will deploy this knowledge to assist Acta clients in achieving and maintaining compliance across multiple global regulatory frameworks. A...

On January 6, 2016, the European Union (EU) published its Commission Implementing Regulation (EU) 2016/9 regarding the joint submission of data and data sharing under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) in the Official Journal of the European Union. The European Commission (EC) Competent Authorities for REACH and CLP (CARACAL) has been developing this Regulation to clarify further what is meant by determining data sharing in a...

Even if Toxic Substances Control Act (TSCA) legislation is not enacted, 2016 will be a momentous year. As the curtain closes on eight years of the Obama Administration, there are a number of items expected to be among the "legacy" issues in the chemical and pesticide regulation space. Enhanced protections for farmworkers, more protective assessment policies, and a re-energized toxic chemical assessment program are among the short list of notable achievements that will have some remaining work to...

What the implementation of new TSCA will look like, along with the general environmental program and emphasis of the new Trump Administration, is very unclear this early in the New Year (the new President will not arrive until January 20). What is more predictable is that the operating environment of OCSPP will change significantly, with uncertain impacts on both the U.S. Environmental Protection Agency’s (EPA) pesticide and toxic chemical regulatory programs. EPA institutionally may never be...

CANADA Stakeholder Roundtables Discuss Supply Chain Communication And SNUR And SNAc Programs: Under the Regulatory Cooperation Council (RCC) work plan for chemicals management, Environment Canada, Health Canada, and the U.S. Environmental Protection Agency (EPA) are collaborating to develop common approaches for regulatory reporting requirements for new uses of chemical substances. The initiative involves work to support supply chain communication...

This analysis reviews the Frank R. Lautenberg Chemical Safety for the 21st Century Act (S. 697) as passed by the Senate on December 17, 2015, and compares it to the previous version of S. 697 (identified as Lautenberg2 in this analysis), passed by the Senate Environment and Public Works (EPW) Committee in June 2015. This review also briefly compares S. 697 to H.R. 2576, the [Toxic Substances Control Act (TSCA)] Modernization Act of 2015, which passed the House of Representatives on...

The December 14, 2015, Chemical Watch article “TSCA Bill Could Have 'Huge' Impact On Downstream Users,” included quotes from Lynn L. Bergeson on possible results of TSCA Reform. Changes to the chemical inventory as proposed in the US Senate Toxic Substances Control Act (TSCA) reform would have a “huge” impact on downstream users, according to Lynn Bergeson, owner of Bergeson & Campbell, PC.  Bill S697 proposes to reset the TSCA Inventory of Chemical Substances to determine which...

The December 14, 2015, Chemical Watch article “TSCA Bill Could Have 'Huge' Impact On Downstream Users,” included quotes from Lynn L. Bergeson on possible results of TSCA Reform. Changes to the chemical inventory as proposed in the US Senate Toxic Substances Control Act (TSCA) reform would have a “huge” impact on downstream users, according to Lynn Bergeson, owner of Bergeson & Campbell, PC.  Bill S697 proposes to reset the TSCA Inventory of Chemical Substances...